Page 1 of 54

NIOSH Response to SC&A’s Review of 

the SEC-00109 LANL Addendum

Response Paper

National Institute for Occupational 

Safety and Health 

September 12, 2018

Chris Miles 

Oak Ridge Associated Universities Team

Reviewed by LaVon Rutherford 

Division of Compensation Analysis and Support

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 2 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

SUMMARY

In the SEC-00109 Evaluation Report Addendum, NIOSH relied heavily on a presumption of 

compliance with 10 CFR Part 835 to conclude that unmonitored workers were unlikely to have 

received intakes of radioactive materials that would have resulted in 100 mrem CEDE per 

year. NIOSH concurs with SC&A’s assessment (SC&A, 2017) that compliance with the 10 CFR 

835 milestone may not be sufficient for demonstrating actual implementation of the 

corresponding radiation monitoring program requirements. NIOSH also concurs that reliance on 

oversight findings may not be sufficient for validating that LANL had fully implemented 10 CFR 

Part 835. Since the issuance of SC&A’s review, NIOSH has compared the available bioassay 

data for monitored LANL workers to the 100 mrem CEDE monitoring threshold and found that 

monitored workers were unlikely to receive 100 mrem CEDE intakes. Also, in response to 

SC&A’s concerns, NIOSH re-emphasizes the significance of LANL’s field monitoring 

programs, which were intended to ensure that unmonitored individuals were unlikely to receive 

intakes of 100 mrem CEDE. These two topics are discussed herein under “NIOSH: Review 

Completed That Supports the Assumption That Unmonitored Worker Intakes Were Not Likely to 

Have Exceeded 100 mrem CEDE.” In conclusion, NIOSH finds that the weight of the evidence 

supports the assumption that unmonitored LANL workers were unlikely to have received intakes 

greater than 100 mrem CEDE per year. For purposes of dose reconstruction for unmonitored 

LANL workers during the 10 CFR 835 era, the assignment of 100 mrem CEDE intakes appears 

to be claimant favorable.

BACKGROUND

On May 4, 2017, SC&A was tasked with reviewing the Addendum to Los Alamos National 

Laboratory (SEC-00109) Special Exposure Cohort Evaluation Report, issued April 24, 2017 

(NIOSH, 2017). This ER Addendum addresses “post-1995 unmonitored intakes of the 

radionuclides for which dose reconstruction limitations were identified in Rev. 1 of the 

SEC-00109 ER,” with the evaluated class remaining the same as in Rev. 1 (NIOSH, 2012) but 

with the start year changed from 1976 to 1996 (NIOSH, 2017). Thus, the evaluated class

defined in the Addendum is: 

Service Support Workers (which includes, but is not limited to, security guards, 

firefighters, laborers, custodians, carpenters, plumbers, electricians, pipefitters, 

sheet metal workers, ironworkers, welders, maintenance workers, truck drivers, 

delivery persons, rad technicians, and area work coordinators) who worked in any 

operational Technical Areas with a history of radioactive material use at the Los 

Alamos National Laboratory from January 1, 1996 through December 31, 2005. 

(NIOSH, 2017, PDF p. 4) 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 3 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

In the Los Alamos National Laboratory (SEC-00109) Special Exposure Cohort Evaluation 

Report, Rev. 1, issued August 13, 2012 (NIOSH, 2012), the National Institute for Occupational 

Safety and Health (NIOSH) selected the class end date of December 31, 1995, based on a 

presumption of full compliance with the U.S. Department of Energy’s (DOE’s) newlypromulgated 10 CFR Part 835, “Occupational Radiation Protection,” which took effect on 

January 1, 1996. In particular, NIOSH refers to 10 CFR 835.402, “Individual Monitoring,” and 

10 CFR 835.702, “Individual Monitoring Records.” 

10 CFR 835.402 states: 

(c) For the purpose of monitoring individual exposures to internal radiation, internal

dosimetry programs (including routine bioassay programs) shall be conducted for: (1)

Radiological workers who, under typical conditions, are likely to receive a committed

effective dose equivalent of 0.1 rem (0.001 sievert) [100 mrem] or more from all

occupational radionuclide intakes in a year” (10 CFR 835.402).

10 CFR 835.702 states: 

(a) Records shall be maintained to document doses received by all individuals for whom

monitoring was required pursuant to §835.402 and doses received during planned special

exposures, accidents, and emergency conditions (10 CFR 835.702).

With full compliance, NIOSH assumes that all DOE work sites, including LANL, would have 

satisfied the monitoring requirements contained in the rule, thereby resolving any limitations that 

make dose reconstruction infeasible prior to that date. For LANL, these limitations included the 

“inability to bound unmonitored intakes of exotic alpha-emitters, fission products, and activation 

products” (NIOSH, 2017, PDF p. 3). Furthermore, with full compliance, NIOSH assumes that 

individual monitoring records would have been maintained and would be available for dose 

reconstruction. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 4 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

PURPOSE AND SCOPE

This white paper serves two functions. It is: 

1. NIOSH’s response to SC&A’s assessment of the LANL ER Addendum and their resulting

conclusions; and

2. an expansion of NIOSH’s original rationale with a focus on the field monitoring programs

and existing bioassay data.

In its review, SC&A viewed the application of the 10 CFR 835 presumptive criterion (for LANL 

and other DOE sites) from two vantage points: 

1. Is the use of 10 CFR Part 835 promulgation a valid basis for presumptive relief from the dose

reconstruction limitations defined in preceding SEC classes for a site such as LANL?

2. Assuming January 1, 1996 as a reasonable milestone for internal dosimetry program

progress, what metrics can be applied to confirm or validate that substantive implementation

of 10 CFR Part 835 was achieved?

This white paper addresses the above two SC&A discussions in turn. NIOSH then expands its 

original rationale in light of those discussions followed by its conclusion. Appendix A contains a 

summary of petitioner issues with their corresponding resolutions.

SC&A: REVIEW OF THE USE OF 10 CFR 835 PRESUMPTIVE CRITERION

In its review, SC&A noted that prior to January 1, 1996, an SEC class was defined for 

1976-1995 with dose reconstruction limitations identified for “exotic alpha-emitters, fission 

products, and activation products” (NIOSH, 2017). These limitations derived from inadequate 

monitoring records, process descriptions, and source-term data to complete internal dose 

reconstructions with sufficient accuracy (ABRWH, 2012a). 

Based on a presumption of compliance with DOE’s then newly-promulgated occupational 

radiation safety rule, 10 CFR Part 835, NIOSH found that dose reconstruction became feasible 

by the rule’s effective date, January 1, 1996. This presumption was based on two key 

provisions of the rule: 

1. Internal dosimetry programs shall be conducted “...for radiological workers who, under

typical conditions, are likely to receive a committed effective dose equivalent of 0.1 rem

(0.001 sievert) [100 mrem] or more from all occupational intakes in a year” (10 CFR

835.402)
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 5 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

2. “...records shall be maintained to document doses received by all individuals for whom

monitoring was required pursuant to §835.402 and doses received during planned special

exposures, accidents, and emergency conditions.” (10 CFR 835.702)

NIOSH’S presumption also relied on other advancements, including LANL’s response to the 

1990 Tiger Team findings and the 1992 development of a Technical Basis Standard for Internal 

Dosimetry.

 

SC&A concluded that NIOSH’s presumption derives from an enforcement milestone, 

beginning in 1996, that would hold LANL accountable for monitoring all workers with a 

likelihood of receiving 100 millirem (mrem) of internal exposure in a year and maintaining 

corresponding records, thereby encompassing those potentially exposed to exotics, mixed 

activation products (MAPs), and mixed fission products (MFPs). This presumption, in turn, 

served as the basis for NIOSH’s conclusion that: 

 “...given the presumption of compliance, the absence of internal dosimetry records 

indicates that unmonitored workers were deemed unlikely to have received intakes 

resulting in a CEDE 0.1 rem or more from all occupational radionuclide intakes in a year” 

(NIOSH, 2017). 

Given NIOSH’s presumptions, SC&A responded with arguments in support of the following 

conclusions: 

1. ...Program compliance with 10 CFR Part 835, while necessary under DOE’s PriceAnderson regulatory framework, is not sufficient for demonstrating that actual radiation

program practice is adequate. ...

...Reliance on oversight findings based on non-compliances or incidents is likewise

necessary, but not sufficient, for validating that LANL or any DOE contractor had

implemented 10 CFR Part 835 in a complete and substantive manner.

2. In summary, while 10 CFR Part 835 provides a clear regulatory milestone with the

Department’s first enforcement mechanism, it was one of several policy milestones for

DOE’s occupational RPP, with the basic provisions being first defined in DOE’s 1989

Order 5480.11. By itself, this regulatory milestone does not necessarily guarantee

conformance with program requirements and expectations for individual monitoring, no

more than did Order 5480.11 and the Radiological Control Manual before it. If anything,

core requirements for and change to how DOE internal dosimetry programs were

implemented did not come until the internal dosimetry technical standard of 10 CFR Part

835 was coupled with an accreditation requirement (for overall dosimetry program
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 6 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

functionality) under DOELAP in the 1998 amendments to the rule, which required all sites 

to achieve accreditation by January 1, 2002.

NIOSH Response:

1. NIOSH concurs with SC&A’s assessment that program compliance may not be sufficient 

for demonstrating implementation of the radiation monitoring program. NIOSH also 

concurs that reliance on oversight findings may not be sufficient for validating that LANL 

had fully implemented 10 CFR Part 835. This appears particularly evident in the multiple 

pertinent findings identified in Noncompliance Report NC ID 484, as SC&A points out later 

in its memorandum. 

Although the focus of the SEC-00109 LANL Addendum is compliance with 10 CFR 835, 

NIOSH does not rely solely on 10 CFR 835 compliance for the conclusion that unmonitored 

workers were unlikely to have received intakes resulting in greater than 100 mrem CEDE. 

The field monitoring and contamination control programs at LANL were well-established 

and formalized by January 1, 1996. A description of these programs, along with a summary 

of associated data available to NIOSH, was included in Section 6.1.1 of the SEC-00109 ER 

Addendum; for the reader’s convenience, this section is reproduced herein under “NIOSH: 

Review Completed That Supports the Assumption That Unmonitored Worker Intakes Were 

Not Likely to Have Exceeded 100 mrem CEDE.” NIOSH also has a substantial amount of 

actual internal dosimetry data for LANL workers. These data show that, for the common 

radionuclides (tritium, uranium, and plutonium), intakes for monitored workers during the 

1996-2005 time period were generally less than 100 mrem CEDE. NIOSH has not found 

any evidence suggesting that the case would be otherwise for unmonitored workers, or that 

intakes of exotic radionuclides would have been higher. A summary of available internal 

dosimetry data and an associated discussion are presented herein under “NIOSH: Review 

Completed That Supports the Assumption That Unmonitored Worker Intakes Were Not 

Likely to Have Exceeded 100 mrem CEDE.” 

2. NIOSH believes that the 10 CFR 835 era represents a paradigm shift in DOE operations. 

Earlier precursors, like DOE Order 5480.11 and the Radiological Control Manual, were 

guidelines and contractual obligations for the contractor. As of January 1, 1996, there was a 

legal requirement, violations of which were subject to criminal and civil penalties under 

Price-Anderson enforcement. 

Although 10 CFR 835 contains a lot of nuances and implementation guides that may have 

come out too late to impact RPP development by January 1, 1996, the important question is 

not overall implementation and compliance with 100 percent of 10 CFR 835, but rather, 

whether there was a program in place ensuring that unmonitored workers were unlikely to 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 7 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

receive intakes resulting in 100 mrem CEDE. This is a very narrow but important subset of 

10 CFR 835. Although there were some bioassay deficiencies identified in LANL audits, 

NIOSH does not find that those issues preclude assigning two percent of the occupational 

exposure limit for workers as a bounding limit for workers who were not monitored. 

NIOSH does not agree that DOELAP accreditation is relevant for full compliance with 

835.402 and 835.702. DOELAP is not a dosimetry standard; it is a performance standard 

tied to ANSI 13.30, Performance Criteria for Radiobioassay. It has nothing to do with the 

100 mrem monitoring requirement; it has to do with how well a laboratory measures an 

analyte in a bioassay sample.

SC&A: REVIEW OF 10 CFR 835 AND INTERNAL DOSIMETRY PROGRAM 

IMPLEMENTATION

In the second part of its review of the LANL ER Addendum, SC&A evaluated NIOSH’s 

presumption that full 10 CFR 835 compliance equated to an occupational radiation 

program operating in 1996–2005 that demonstrably resolves the dose reconstruction 

limitations previously identified for the site. Toward this end, SC&A asked three question 

ns and provided their conclusions (summarized below). 

Q1: Was the LANL occupational radiation program that was deemed compliant with 

10 CFR 835 fully defined, evaluated, and independently reviewed and certified 

prior to January 1, 1996? 

SC&A concludes that both LANL and DOE followed a deliberate review and verification 

process for validating compliance with 10 CFR Part 835 prior to final enactment on 

January 1, 1996. However, it is apparent that uniform acceptance criteria (i.e., 

implementation guidance) were not available in time for use in the field and that wide 

latitude was apparently given to LANL and other DOE sites to interpret how 10 CFR 

Part 835 was to be applied to occupational RPPs. Therefore, that compliance review, at 

the time, may not have been adequate to validate the conformity of existing LANL 

dosimetry programs to corresponding dosimetry requirements in the rule.

NIOSH Response:

NIOSH concurs with SC&A’s assessment that compliance review, at the time, may not 

have been adequate to validate total conformity of existing LANL dosimetry programs to 

corresponding dosimetry requirements in 10 CFR 835. However, NIOSH does not find 

that the potential lack of complete conformity precludes assigning two percent of the 

occupational exposure limit for workers as a bounding limit for workers who were not 

monitored. Again, existing data for monitored workers during this time period indicate that 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 8 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

monitored workers were unlikely to receive intakes resulting in 100 mrem CEDE. NIOSH 

believes that the unmonitored worker population would have had a lower potential for 

exposure than the monitored population. This issue is discussed in more depth herein 

under “NIOSH: Review Completed That Supports the Assumption That Unmonitored 

Worker Intakes Were Not Likely to Have Exceeded 100 mrem CEDE.” 

Q2: Is there any evidence of site-specific or general non-conformances with 10 CFR 

835 that would have substantive implications for dose reconstruction within the 

LANL occupational RPP following the effective implementation of the rule on 

January 1, 1996? 

SC&A’s review scope went beyond site-specific findings to include more general 10 CFR 

835 non-conformance issues stemming from experiences at other DOE sites that may have 

implications for LANL.

SC&A reviewed LANL self-assessments, DOE and DNFSB oversight reviews, nonconformance reports from the DOE Office of Enforcement, and contractor and DOE 

reporting systems, such as the DOE ORPS and DOE NTS. Non-conformance Report NC 

ID 484 was specifically identified as having substantive implications for dose 

reconstruction: 

Noncompliance report NC ID 484 was based on an assessment of the LANL internal dose 

evaluation program conducted by representatives from Savannah River Site (SRS), MJW 

Corporation, LANL’s Radiation Protection Services Group (ESH-12), and Quality 

Assurance Group (ESH-14) on March 22–25, 1999. The assessment had 10 

noncompliance findings, summarized as follows (DOE/NTS 2017), the first three of 

which impaired LANL’s ability to monitor individuals “likely to receive a committed 

effective dose equivalent of 0.1 rem (0.001 sievert) or more from all occupational 

radionuclide intakes in a year” (10 CFR 835.402(c)(1)). 

The three findings that SC&A identified as particularly problematic are:

1. Some workers and their supervisors are not accurately completing the 

“health physics checklist” (utilized for enrolling workers into dosimetry 

programs) to the extent that these checklists may not identify those 

radionuclides actually handled by the worker. Thus, some workers are not 

being assigned to the appropriate routine bioassay program in accordance 

with site requirements. [835.402(c)(1)] 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 9 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

2. Some radiological workers are not complying with specific RWPs that require 

them to participate in a bioassay program. As an example, two out of five 

workers who performed work under a specific RWP did not participate in the 

bioassay program in accordance with requirements of the RWP. 

[835.402(c)(1)] 

3. Johnson Controls of Northern New Mexico (JCNNM), the principle 

[sic] subcontractor to Los Alamos National Laboratory, may not be 

enrolling all workers who are potentially exposed to radionuclides into 

the appropriate bioassay program in accordance with site 

requirements. [835.402(c)(1)]

SC&A noted the subsequent corrective actions were undertaken and closed by 2000. In 

SC&A’s view, the above non-compliances and subsequent corrective actions are important 

to the LANL bioassay program, quite apart from 10 CFR 835 compliance, and evince 

likely longstanding implementation issues with that program: 

SC&A concludes that the 1999 LANL noncompliance notwithstanding (which derived 

from an independent review with outside reviewers), solely relying on the lack of Notices 

of Violation (NOVs) and other recorded non-conformances as a benchmark of effective 

RPP implementation is questionable. Key provisions of 10 CFR Part 835, e.g., 

application of the 100 mrem criterion under 835.402(c)(1), do not lend themselves easily 

to assessment and verification by external compliance reviews, incident occurrences, or 

procedure reviews. Traditional validation and verification sampling for adequacy and 

completeness, and interviews with workers and radiation protection personnel, have 

proven effective in the past to establish the status of program implementation. 

NIOSH Response:

NIOSH concurs with SC&A’s assessment that solely relying on the lack of Notices of 

Violation (NOVs) and other recorded non-conformances as a benchmark of effective RPP 

implementation is questionable. This appears particularly evident in the 1999 independent 

review (Assessment, 1999) that resulted in the pertinent findings identified in Noncompliance Report NC ID 484 (Non-conformance, 1999). 

Although the focus of the SEC-00109 LANL ER Addendum is compliance with 10 CFR 

835, NIOSH does not rely solely on 10 CFR 835 compliance for the conclusion that 

unmonitored workers were unlikely to have received intakes resulting in greater than 100 

mrem CEDE. LANL’s field monitoring programs were designed and implemented for the 

purpose of ensuring that unmonitored individuals were unlikely to receive intakes of 100 

mrem CEDE. Also, as mentioned previously, NIOSH has a substantial amount of internal 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 10 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

dosimetry data for LANL workers. These data show that intakes for monitored workers 

during the 1996-2005 time period were generally less than 100 mrem CEDE and NIOSH 

believes that intakes for unmonitored workers would likely be even lower. Discussions 

regarding LANL’s field monitoring programs and available bioassay data for monitored 

LANL workers are included herein under “NIOSH: Review Completed That Supports the 

Assumption That Unmonitored Worker Intakes Were Not Likely to Have Exceeded 100 

mrem CEDE.”

Q3: Are there any LANL occupational protection program or internal dosimetry 

program implementation issues identified after January 1, 1996 that may hamper 

or preclude dose reconstruction? These would include concerns identified in the 

ER, including neptunium and special tritium compounds. 

SC&A originally raised concerns about exotic alpha-emitters, fission products, and 

activation products in its 2010 focused review of the LANL evaluation report (SC&A 

2010). That review noted that as far back as in its 2006 site profile review, SC&A had 

found that “inadequate consideration was given to potential exposure and missed dose 

from radionuclides other than the ‘well documented’ ones cited in the TBD (e.g., 

plutonium, polonium, tritium, etc.)” (SC&A 2010, page 8). This was borne out in terms of 

LANL practice from interviews with LANL staff and other experts; a summary of findings 

from those interviews is provided below (SC&A 2010): 

• It is fairly well recognized that most DOE facilities, such as LANL, Rocky 

Flats Plant (RFP), etc., had the capability to detect, identify, and quantify 

MFP/MAP in workers beginning in the early 1970s. However, it is not as 

certain (or as well documented) that it was standard practice to actually 

analyze and record the activity from these radionuclides in the worker’sfile.

• MFP/MAP activities appear to have been investigated in certain situations, 

but it has not been documented that it was performed on a routine basis at 

LANL.

• Prior to 1998, LANL primarily relied upon the Phoswich detectors for in-vivo 

(whole-body or lung-counting) measurements. An in-vivo count spectrum was 

typically not analyzed for fission or activation product radionuclides, unless a 

peak associated with a certain nuclide was visible in the spectrum, or LANL 

knew or suspected that an exposure had occurred. When that peak was 

identified, the nuclide was added to the radionuclide library, and the spectrum 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 11 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

was converted to activity and reported in the record. Identification of a peak 

could be subjective at times and not directly correlated to MDA [minimum 

detectable activity] or critical levels, especially with the broad peaks that 

appeared in the photon spectra, because of the low resolution of these 

scintillation-type detectors.

• Phoswich detectors were unable to resolve peaks for exotic and MFP or MAP 

radionuclides, particularly those that emitted low-energy photons. 

• To overcome the detector’s inability to resolve peaks, LANL set up regions of 

interest for the photon spectra, and used control groups of non-nuclear 

workers to estimate body and room background contributions, and to 

statistically determine net counts above background and identify peaks of 

interest.

• After germanium detectors became available, if a known or suspected 

exposure had occurred, then measurements were repeated with highresolution germanium detectors to verify and identify the presence of a 

radionuclide if the peak was determined not to be one of the primary 

radionuclides. If detected, the radionuclide was added to the analysis library 

and confirmed as a positive identification that needed a dose assessment. In 

most of the cases, in-vitro bioassay samples were also collected.

• There is a higher likelihood that peaks could have been missed when the 

germanium detectors were not in operation or had not yet been installed (i.e., 

before 1998). 

• A programmatic assessment of the internal dosimetry program by DOE in 

2001 found that thorium-232 and the short-lived MAP radionuclides 

generated at the Los Alamos Neutron Science Center (LANSCE), although 

required for routine internal dosimetry evaluation, were not included in the 

in-vivo program library (DOE, 2001). The absence of this routine 

monitoring capability as late as 2001 brings into question the ability of the 

LANL program to detect these and other exotics on a routine basis as a 

matter of practice (vs. technical capability). As DOE noted in its finding, 

“Without this information, the in-vivo laboratory cannot identify monitoring 

strategies or ensure adequate energy calibrations;” and that “interviews with 

the in-vivo staff indicated that they were not aware of the need for this

capability.” 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 12 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

SC&A contends that these and related concerns likely contributed to the lack of 

monitoring records for MFPs and MAPs. 

In discussing the oversight finding that Th-232 and MAPs generated at LANSCE were 

not included in the in-vivo program library, SC&A closed with the following statement: 

This may not have been of great consequence after the introduction of more sensitive 

germanium detectors in 1998, but it clearly may have hampered in vivo monitoring for 

these radionuclides before that time when Phoswich detectors were being relied upon.

The section concluded with the following statement:

SC&A concludes that there is no evidence that the internal dosimetry and monitoring 

shortfalls cited in deliberations that led to the recommendation by the Advisory Board to 

define an SEC class for 1976–1995 (ABRWH 2012b) have been resolved for the time 

period after 1995.

NIOSH Response:

NIOSH does not share many of the concerns identified by SC&A in this section. It 

appears that SC&A was not aware of the extensive use of high-resolution germanium 

detectors for in-vivo counting at LANL throughout the period evaluated in the SEC-00109 

ER Addendum. Germanium detectors had been widely used at LANL for in-vivo

measurements since the mid-1970s, long before the period under evaluation in the 

addendum. The configuration of the lung-counting system is illustrated in the 1984 

LANL document LA-9979-MS, In Vivo Assessment of Lung Burdens at the Los Alamos 

National Laboratory (LANL, 1984). Although it is true that Phoswich detectors were 

used as late as 1998, they were used in conjunction with germanium detectors and not 

exclusively relied upon.

NIOSH acknowledges that there were very few bioassay or other internal dose assessments 

for exotic radionuclides. This is true for the entire period of LANL operations. This was 

the primary driver for NIOSH’s recommendation to extend the LANL SEC through 1995 

in Rev. 1 of the SEC-00109 ER. The ER Addendum presents a methodology for

performing dose reconstructions for exotic radionuclides for LANL workers in the absence 

of bioassay during the 10 CFR 835 era. Based on the available information that NIOSH 

has collected regarding LANL operations, use of exotic radionuclides at LANL was 

relatively rare, not nearly as prevalent as the use of the primary radionuclides (plutonium, 

uranium, and tritium), for which there is an abundance of bioassay data. As pointed out in 

SC&A’s memorandum, LANL noted that its internal dosimetry monitoring programs are 

established on an as-needed basis and that monitoring is only required for radiological 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 13 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

workers likely to receive 100 mrem annually from internal exposure (LANL 2013). LANL 

further notes: 

LANL has an in vivo monitoring program established for fission products and activation 

products, and has historically used in vivo monitoring for these radionuclides. A spectral 

analysis of each count was performed by the in vivo staff. During this review, all peaks 

were identified and quantified. [LANL 2013, page 3] 

Regarding the 2001 DOE oversight finding concerning LANL’s capability to monitor for 

MAPs generated at LANSCE, NIOSH does not share SC&A’s concern. LANL has used 

germanium detectors extensively for body counts for LANSCE workers beginning in 

March 1979. A summary of the bioassay data available to NIOSH is presented in the 

LANL Bioassay Repository Database (ORAUT-OTIB-0063). This database includes 

106,950 in-vivo records. The vast majority of these are counts for Am-241 (41%) and 

Pu-239 (41%). The next largest contributors to the total number of in-vivo records are 

U-235 and Th-234 (5% each). The bulk of the remaining 7000+ records is primarily 

comprised of fission and activation product radionuclides for LANSCE employees that 

were acquired via germanium detectors. The in-vivo records in the LANL bioassay 

database specify 81 different analytes. A summary of the in-vivo counting records from 

1969 through 2005 are listed below. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 14 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

Analytes Listed for In-Vivo Counting Records in the ORAU Team’s Database

Analyte Total Records 

for 1969-2005

Records with Count 

Dates from 1969-1995

Records with Count 

Dates from 1996-2005

Am-241 40796 28712 12084

As-72 3 3 0 

Ba-140 0 0 0 

Be-7 819 690 129

Bi-213 14 0 14

Bi-214 6 6 0 

Br-76 12 11 1 

Br-77 17 16 1 

C-11/N-13 1308 758 550

Cd-109 19 18 1 

Ce-141 8 7 1 

Cf-249 9 9 0 

Cm-244 1 0 1 

Co-56 1 1 0 

Co-57 8 8 0 

Co-57/Co-58 1 1 0 

Co-58 6 6 0 

Co-60 73 43 30

Cr-51 1 1 0 

Cs-134 127 127 0 

Cs-137 436 353 83

Cu-64 1 1 0 

Cu-67 1 1 0 

Eu-152 451 27 424

Fe-59 1 1 0 

Fission prods 1 1 0 

Gd-146 0 0 0 

Gd-153 0 0 0 

Ge-67/Ga-67 1 1 0 

Ge-68/Ga-68 5 5 0 

Hf-173 3 0 3 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 15 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

Analyte Total Records 

for 1969-2005

Records with Count 

Dates from 1969-1995

Records with Count 

Dates from 1996-2005

Hf-175 5 0 5 

Hg-195M 8 7 1 

Hg-197 40 39 1 

Hg-197M 8 7 1 

Hg-203 25 24 1 

I-123 2 2 0 

I-125 159 159 0 

I-131 13 13 0 

I-132 1 1 0 

La-140 0 0 0 

Lu-172 0 0 0 

Lu-173 0 0 0 

Mn-54 773 649 124

Na-22 1178 636 542

Na-24 6 6 0 

Nb-95 0 0 0 

Nd-147 8 7 1 

Os-185 11 10 1 

P-32 2 2 0 

Pb-212 15 1 14

Pb-214 14 0 14

Pu-238 109 109 0 

Pu-238/Pu-239 2 2 0 

Pu-239 39848 27863 11985

Ra-226 4 3 1 

Rb-83 13 12 1 

Rb-84 11 10 1 

Sb-124 11 10 1 

Sc-46 8 8 0 

Se-72/As-72 1 1 0 

Se-75 32 31 1 

Sm-145 8 7 1 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 16 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

Analyte Total Records 

for 1969-2005

Records with Count 

Dates from 1969-1995

Records with Count 

Dates from 1996-2005

Ta-179 9 8 1 

Ta-182 0 0 0 

Te-132 1 1 0 

Th-234 2567 0 2567

Tl-201 11 10 1 

Tl-202 14 13 1 

Tungsten 1 1 0 

U-235 2572 1 2571

U-237 7 7 0 

U-238 3 2 1 

Unidentified 2 2 0 

V-48 4 4 0 

Yb-169 0 0 0 

Zn-65 11 11 0 

Zr-95 1 1 0 

Zr-95/Nb-95 3 3 0 

The SC&A memorandum also expressed concern about the 2001 DOE oversight finding 

regarding LANL’s ability to monitor for Th-232. In response to NIOSH requests for 

information to demonstrate LANL’s capability to monitor for various radionuclides

(including Th-232), LANL indicated that there are no workers on a routine thorium 

bioassay program because it is not warranted (i.e., workers are unlikely to receive thorium 

intakes resulting in greater than 100 mrem CEDE). LANL also provided an example of 

“targeted” in vivo Th-232 bioassay for an international traveler in 1999 (Th-232 Bioassay, 

1999). This whole-body count result from March 1999 clearly demonstrates LANL’s 

capability to monitor for Th-232 using in-vivo methods prior to the 2001 DOE oversight 

finding. NIOSH concludes that this capability was likely present for the duration of the 

period under evaluation (1996-2005). 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 17 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

Special Tritium Compounds and Neptunium

For special tritium compounds (STCs), SC&A agreed with NIOSH’s assessment that 

LANL was aware of their presence in the late 1990s and took measures to communicate 

appropriate dose assessment considerations within the LANL health physics program and 

to DOE. The potential for significant exposure was deemed small and handled on a 

case-by-case basis. The capability for NIOSH to bound intakes of STCs exists, if found 

necessary, and methods are available (e.g., ORAUT-OTIB-0066) by which dose 

reconstruction can be performed. 

For neptunium, SC&A did not necessarily agree with NIOSH’s conclusion that the RPP 

inadequacies found by the DOE Office of Independent Oversight (LANL Inspection, 

2005) “do not indicate that unmonitored intakes occurred” (NIOSH, 2017). SC&A found 

premature any conclusion regarding potential exposure from, and monitoring for, 

neptunium founded on findings from one facility and a particular oversight investigation, 

without ascertaining site-wide inventories and the full scope of operations that may have 

handled neptunium. 

NIOSH Response:

NIOSH has fully evaluated the neptunium operations of concern to the petitioner. This 

evaluation was summarized in the ER Addendum (NIOSH, 2017). The possibility that 

there may have been other neptunium operations of which NIOSH is unaware cannot be 

dismissed. However, given LANL’s awareness of this issue and its limited case-by-case 

exposure potential, NIOSH maintains that intakes resulting in 100 mrem CEDE would 

likely be bounding for any such operation. 

NIOSH: REVIEW COMPLETED THAT SUPPORTS THE ASSUMPTION THAT 

UNMONITORED WORKER INTAKES WERE NOT LIKELY TO HAVE EXCEEDED 

100 MREM CEDE

In response to SC&A’s concerns, NIOSH re-emphasizes the significance of LANL’s 

field monitoring programs, which were intended to ensure that unmonitored individuals 

were unlikely to receive intakes of 100 mrem CEDE. Also, since the issuance of 

SC&A’s review, NIOSH has compared the available bioassay data for monitored 

LANL workers to the 100 mrem CEDE monitoring threshold and found that monitored 

workers were unlikely to receive 100 mrem CEDE intakes. These two topics are 

discussed below.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 18 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

LANL Field Monitoring and Contamination Control Programs 

The field monitoring and contamination control programs at LANL were wellestablished and formalized by January 1, 1996. A description of these programs, along 

with a summary of associated data available to NIOSH, was included in Section 6.1.1 

of the SEC-00109 ER Addendum. For the reader’s convenience, this section is 

reproduced below.

ER Addendum, Section 6.1.1: Field Monitoring Program and Associated Data

By January 1, 1996, the health physics field monitoring and contamination control programs 

at LANL were well established and formalized, with over 60 procedures addressing various 

aspects of radiological protection (LANL Procedures, 1996), as well as an established 

process for tracking and notifying staff of revisions (Procedure Revisions, 1996). These 

procedures cover program administration, exposure and contamination control, monitoring, 

instrumentation, protective equipment, emergency response, and the As Low As Reasonably 

Achievable (ALARA) program.

In addition to site-wide procedures, area-specific procedures and instructions were also in 

effect. For example, the stated purpose of the ESH-1/TA-55 Radiation Monitoring 

Instructions is “to provide survey frequencies which are to be used by the ESH-1 

Radiological Control Technicians (RCTs) and Health Protection Technicians (HPTs) in 

assisting the NMT Division in the implementation of the radiological control program at TA55” (TA-55 Instructions, 2000). This document defines the routine monitoring tasks of the 

RCTs assigned to TA-55 and delineates responsibilities. Routine surveys are described with 

survey frequencies ranging from daily to annually. These instructions also specify types of 

routine external radiation surveys, as well as air monitoring and TA-55 Technical Safety 

Requirements (TSRs), which include annual CAM system calibration, monthly performance 

tests, and daily operability checks. 

NIOSH has obtained hundreds of radiological protection documents from LANL for the time 

period under evaluation. Examples include: 

• Radiological Work Permits requiring contamination surveys and air monitoring (RWPs,

1997; RWPs, 2003)

• Monthly contamination surveys (Monthly Surveys, 1998; Monthly Surveys, 1999)

• Area-specific contamination surveys (TA-3 Survey Results, 1999; TA-18 Survey Results,

1997)
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 19 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

• Quarterly contamination survey summaries (Quarterly Summaries, 1999; Quarterly

Summaries, 2003)

• Area-specific monitoring data quarterly reviews (CMR Quarterly Review, 1996; TA-55

Quarterly Review, 1995-1996)

• Air sample analysis data (Air Data, 1996-1997; Air Data, 2001)

• Air sampling/monitoring technical evaluations (Air Sampling Evaluation, 2001a; Air

Sampling Evaluation, 2001b)

• Airborne radioactivity investigation reports (Airborne Radioactivity, 2001; Airborne

Radioactivity, 2002)

• Task-specific radiological protection assessments/checklists (ESH-1 Checklist, 2001; Rad

Protection Checklist, 1995)

• Standard operating procedures (SOP) tracking (SOP Matrices, 1996; SOP Revisions,

1996)

[End ER Addendum, Section 6.1.1] 

During multiple data capture efforts, NIOSH found many boxes of LANL RWP records. 

Although it did not attempt to capture or review each and every one of these records, NIOSH did 

capture what it feels is a representative sample. Consequently, the NIOSH database contains 

several hundred LANL RWPs for the 1996-2005 time period, consisting of thousands of pages of 

records. Much of the focus during these data capture efforts was on finding RWPs that involved 

non-routine radionuclides (i.e., other than plutonium, uranium, and tritium), although many 

RWPs involving these more common nuclides were also collected. 

Some general statements can be made regarding the LANL RWPs issued during the time period 

under evaluation: 

• Most of these RWPs required pre-job and/or post-job contamination surveys, and the

associated smear records are included in the captured documentation.

• Most of them specified PPE to be worn.

• Many of them specified respiratory protection.

• Most of them required at least some RCT coverage and included stop work or hold points

that would invoke re-evaluation.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 20 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

• Most of the work was conducted in areas where continuous air monitors (CAMs) were in

operation.

• Many of the RWPs required other job-specific air monitoring or breathing-zone air

monitoring, and the associated monitoring records are included in the captured

documentation.

• Several of them required nasal smears to be taken.

In general, bioassay requirements were not routinely specified on RWPs. The RWPs appear to 

have been designed to minimize the likelihood of intakes via engineering controls, PPE, and 

respiratory protection. The RWPs were also designed to detect material release via air 

monitoring and smear surveys. Elevated surface or airborne contamination would trigger an 

assessment for the need for bioassay.

Occurrence Report No. DP-ALO-LA-LANL-TA55-2002-0003 describes an event in TA-55 in 

2002 that resulted in airborne release of radioactive material and internal exposure to employees 

(ORPS, 2002). The operation was performed under RWP 02-55-319-7 (not available in the 

NIOSH database). The description provided in the occurrence report (reproduced below) clearly 

shows a scenario whereby field indicators, including a CAM alarm, personnel contamination 

surveys, and nasal smears led to bioassay assessments.

MANAGEMENT SYNOPSIS: On Wednesday, March 13, 2002, at approximately 1540 hours, 

at Technical Area 55, Building 4 (TA-55-4), two employees were detected with contamination 

in their nasal passages, as indicated by nasal swipes, one of whom also had skin 

contamination, after evacuating Room 319 after a Continuous Air Monitor (CAM) alarmed 

indicating airborne contamination. All contamination was alpha. The first employee (E1), 

from Weapons Component Technology (NMT-5), had skin and hair contamination up to 

5,000 disintegrations per minute (dpm) and nasal smear readings of 1,389/No Detectable 

Activity (NDA) dpm. The second employee (E2), from Engineering Sciences and 

Applications (ESA), had no skin contamination but nasal smear readings of 32/92 dpm. E2 

had been working approximately 5-10 feet from E1. Thirteen employees were in the room at 

the time of the CAM alarm. No other personnel contamination was detected. E1 and E2 

were placed on prompt bioassay on Thursday, March 14, 2002. Field indicators were 

evaluated to determine appropriate special bioassay requirements for all other employees 

present in Room 319 at the time of the release. Based on the pattern of the release, as 

indicated by FAS filter analysis, additional employees were placed on special bioassay. A 

total of seven employees were placed on bioassay. The preliminary results of the bioassays 

were received on Wednesday, April 17, 2002. The preliminary estimates indicated 50-year 

Committed Effective Dose Equivalent (CEDE) ranging from 2 mrem to 14 mrem. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 21 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

In a 1998 Occurrence Report, ALO-LA-LANL-CMR-1998-0041, from the CMR facility, the 

description (reproduced below) shows another scenario in which field monitoring led to bioassay 

assessment (ORPS, 1998). This operation was performed under RWP Number 98-3-29-2114-

285 (not available in the NIOSH database). 

MANAGEMENT SYNOPSIS: On November 10, 1998, at 1600, Chemistry and Metallurgy 

Research (CMR) facility management was notified that alpha activity measuring up to 

56,000 disintegrations per minute/100 square centimeters (cm[2]) had been detected on a 

Material Research & Processing (NMT-11) employee's personal clothing. The 

NMT-11employee had been removing legacy items from a chemical fume hood in Wing 2, 

room 2114, of the CMR facility. The principal contaminant was subsequently determined to 

be americium-241. 

Radiological control technicians (RCTs) assisted the NMT-11 employee with changing into 

clean clothing. The contaminated clothing will be properly discarded. The NMT-11 

employee submitted nasal smears; results were 36/0 dpm-alpha. Based on the nasal smear 

results, the employee was placed on a special bioassay program and restricted from working 

in radiologically controlled areas pending preliminary bioassay results and radiation dose 

assessment. 

Available Bioassay Data for Monitored LANL Workers 

Radiation dosimetry monitoring requirements for LANL workers were well-established prior to 

the implementation of 10 CFR 835. The 1991 LANL Environment, Safety, and Health Manual 

indicates the need for bioassay monitoring of personnel in order to demonstrate compliance with 

radiation protection standards (ES&H Manual, 1991). That document includes action levels for 

worker monitoring that required routine bioassay for workers with the potential to receive “0.1 

rem annual effective dose equivalent from internal sources” or “5 rem annual dose equivalent to 

any organ or tissue from internal sources.” LANL’s 1994 Radiation Dosimetry Monitoring 

Laboratory Standard (LANL Dosimetry, 1994) specifies bioassay monitoring requirements. It 

includes operations that would trigger bioassay and determinations based on quantities and forms 

of radioactive materials at risk. A table presented in that document indicates that any positive in 

vivo whole-body count will require an assessment of intake. The table shows the recommended 

counting interval necessary to detect 2% of an ALI for 26 different gamma-emitting 

radionuclides. Routine contamination survey and air monitoring programs were in place to 

ensure that personnel monitoring was appropriate for the various areas, and boundaries were 

established so that unmonitored personnel would not likely receive 100 mrem CEDE. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 22 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

NIOSH reviewed the DOE Occurrence Reporting System for LANL 10 CFR 835 violations, site 

responses, and corrective actions. A total of 159 documents were accessed (ORPS Reports, 

1993-2015). NIOSH also reviewed the DOE Non-conformance Tracking System for LANL 

10 C.F.R. pt. 835 violations, site responses, and corrective actions. A total of 384 documents 

were captured (NTS List, 2016). As a consequence of the field monitoring programs, workers 

were often required to undergo bioassay. This was clearly evident from the numerous ORPS 

reports reviewed by NIOSH.

A class of LANL workers has been added to the Special Exposure Cohort due to a lack of 

available bioassay data for “exotic” radionuclides. This class includes all workers from the 

beginning of site operations in 1942 through 1995. This lack of bioassay data for “exotic” 

radionuclides has continued to persist to the present time. LANL has contended that bioassay 

data for exotic radionuclides are scarce because it is and has been unwarranted, especially during 

the 10 CFR 835 era. It is deemed unwarranted, according to LANL health physics professionals, 

because workers are unlikely to have received intakes resulting in 100 mrem CEDE from these

radionuclides in any given year; therefore, workers were not required to have been monitored for 

them. 

In the SEC-00109 LANL ER Addendum, NIOSH proposed a method for assigning bounding 

intakes of these exotic radionuclides for LANL workers in the absence of bioassay data. The 

method proposed was to assign annual intakes for these radionuclides that would have resulted in 

100 mrem CEDE. The primary basis for this proposed method was the legal requirements set 

forth in 10 CFR 835 that went into effect on January 1, 1996. 

In SC&A’s review of the SEC-00109 LANL ER Addendum, SC&A pointed out multiple issues 

regarding LANL’s technical ability to monitor for various radionuclides and examples of 

oversight findings where perhaps workers should have been monitored for internal dose 

according to the 10 CFR 835 rule, but apparently were not. NIOSH shares some of the concerns 

from the oversight findings, as discussed above in this document. In light of these concerns, the 

primary question still remains. Is the assignment of 100 mrem CEDE intakes for unmonitored 

workers likely to be bounding? 

In an attempt to help answer this question, NIOSH believes it useful to take a look at the primary 

LANL radionuclides, tritium, plutonium isotopes, and uranium isotopes - radionuclides for 

which bioassay data are abundant. There are over 450,000 LANL urinalysis records available to 

NIOSH for the period 1945 through 2008. These include data for plutonium, polonium, 

uranium, and tritium. In addition, there are over 100,000 in-vivo records. These data are 

presented and evaluated in the Internal Dosimetry Coworker Data for Los Alamos National 

Laboratory (ORAUT-OTIB-0062). 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 23 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

The following six tables, reproduced from ORAUT-OTIB-0062, give intake values to be used in 

dose reconstruction for unmonitored LANL workers for any given year. The values are based on 

the available co-worker bioassay data, and represent 50th percentile exposures. For tritium, the 

actual annual dose equivalent (mrem) is provided. For isotopes of plutonium and uranium, 

intake rates in units of picocurie per day (pCi/d) are provided. 

Note: A feature worth noting in these tables is that intake rates have trended lower over the 

years at LANL. Post-1995 intakes for monitored workers can be seen to be relatively low 

in comparison to intakes during LANL’s earlier years. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 24 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

Table 5-1 from ORAUT-OTIB-0062: Tritium Annual Doses (mrem) and GSDs

Year Dose GSD

1950 33 7.2

1951 36 5.9

1952 25 4.2

1953 26 6.7

1954 16 6.2

1955 43 6.5

1956 33 6.9

1957 35 6.9

1958 26 5.7

1959 22 5.5

1960 27 5.2

1961 20 4.7

1962 17 4.7

1963 18 3.7

1964 17 3.5

1965 18 3.5

1966 19 4.2

1967 23 6.0

1968 16 4.6

1969 21 5.0

1970 25 7.0

1971 16 4.9

1972 14 5.4

1973 16 5.3

1974 25 6.7

1975 19 6.2

1976 13 4.1

1977 20 5.5

1978 20 5.2

1979 12 4.9

1980 15 4.1

1981 17 4.1
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 25 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

Year Dose GSD

1982 21 4.5

1983 18 4.8

1984 16 3.4

1985 18 3.3

1986 21 3.8

1987 17 4.3

1988 7 4.4

1989 7 3.5

1990 6 3.2

1991 2 3.0

1992 5 3.5

1993 6 3.4

1994 3 3.0

1995 5 3.0

1996 5 3.0

1997 4 3.0

1998 7 3.0

1999 4 3.0

2000 9 4.1

2001 6 3.0

2002 6 3.5

2003 5 3.3

2004 3 3.0

2005 3 3.0

2006 4 3.0

2007 4 3.0

2008 6 3.3
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 26 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

Table 5-2 from ORAUT-OTIB-0062: Plutonium-238 Intake Rates (pCi/d)

Start End Type M 50th 

Percentile Type M GSD Type S 50th Percentile Type S GSD

1/1/1968 12/31/1971 1.8 5.63 43 5.74

1/1/1972 12/31/1972 14. 3.13 765 3.13

1/1/1973 12/31/1974 2.0 4.31 72 4.17

1/1/1975 12/31/1977 0.67 3.59 5.2 8.47

1/1/1978 12/31/1981 0.32 7.56 5.2 8.47

1/1/1982 12/31/1988 0.084 8.73 1.8 8.47

1/1/1989 12/31/1993 0.44 4.31 9.7 4.17

1/1/1994 12/31/2008 0.048 6.82 0.72 6.58

Table 5-3 from ORAUT-OTIB-0062: Plutonium-239 Type M Intake Rates (pCi/d)

Start End Type M 50th 

Percentile Type M GSD

1/1/1944 12/31/1945 248 5.05

1/1/1946 12/31/1946 95 6.24

1/1/1947 12/31/1953 10 5.16

1/1/1954 12/31/1954 3.1 17.2

1/1/1955 12/31/1956 3.1 12.4

1/1/1957 12/31/1966 0.38 12.4

1/1/1967 12/31/1972 3.3 4.81

1/1/1973 12/31/1975 1.5 6.21

1/1/1976 12/31/1993 0.16 6.83

1/1/1994 12/31/2008 0.013 12.2
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 27 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

Columns 1-4 from Table 5-4 from ORAUT-OTIB-0062:Pu-239 

Type S and Super S Systemic Intake Rates (pCi/d)

Start End 50th 

Percentile GSD

12/31/1945 8,651 a 5.05

1/

1/1/1944

1/1946 12/31/1946 5,125 a 6.24

1/1/1947 12/31/1953 200 a 4.87

1/1/1954 12/31/1954 88a 11.12

1/1/1955 12/31/1956 88a 15.3

1/1/1957 12/31/1966 6.3a 11.91

1/1/1967 12/31/1972 73a 4.62

1/1/1973 12/31/1975 41 a 6.34

1/1/1976 12/31/1993 2.3 a 6.34

1/1/1994 12/31/2008 0.14 a 12.8

a. Urinalysis-based intake rates.

Columns 5-8 from Table 5-4 from ORAUT-OTIB-0062: Pu-239 

Type S and Super S Non-Systemic Intake Rates (pCi/d)

Start End 50th 

Percentile GSD

1/1/1944 12/31/1945 8,651a 5.05

1/1/1946 12/31/1946 5,125a 6.24

1/1/1947 12/31/1953 200a 4.87

1/1/1954 12/31/1954 88a 11.12

1/1/1955 12/31/1956 88a 15.3

1/1/1957 12/31/1966 6.3a 11.91

1/1/1967 12/31/1968 73a 4.62

1/1/1969 12/31/1971 27.66b 4.50

1/1/1972 12/31/1974 29.43b 4.50

1/1/1975 12/31/1975 505.4b 3.00

1/1/1976 12/31/1977 96.07b 3.90

1/1/1978 12/31/1979 19.55b 6.24

1/1/1980 12/31/1993 2.3a 6.34

1/1/1994 12/31/2008 0.14a 12.8

a. Urinalysis-based intake rates.

b. Lung count-based intake rates.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 28 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

Table 5-7 from ORAUT-OTIB-0062: Uranium Intake Rates (pCi/d)

Start End Type F 50th P 

Percentile

Type F 

GSD

Type M 50th 

Percentile

Type M 

GSD

Type S 50th 

Percentile

Type S 

GSD

1/1/1947 12/31/1949 21.3a 3.36 88.7a 3.36 1,520a 3.24

1/1/1950 12/31/1955 21.3 3.36 88.7 3.36 1,520 3.24

1/1/1956 12/31/1957 5.36 3.36 16.0 3.36 656 3.24

1/1/1958 12/31/1965 1.98 4.81 7.95 4.90 141 4.71

1/1/1966 12/31/1973 0.909 6.84 3.53 7.03 59.3 6.59

1/1/1974 12/31/1982 0.227 11.31 1.03 10.6 19.7 9.27

1/1/1983 12/31/1989 1.53 4.81 6.29 4.90 105 4.44

1/1/1990 12/31/2000 0.201 4.03 0.756 4.06 11.0 4.57

1/1/2001 12/31/2001 1.019 3.00 4.70 3.00 92.0 3.00

1/1/2002 12/31/2008 0.201 4.03 0.756 4.06 11.0 4.57

a. Intakes for 1947 through 1949 are based on the 1950 through 1955 intakes.

The SEC-00109 LANL ER Addendum proposed annual intakes of 2% SALI as bounding intake 

quantities for unmonitored workers with access to controlled areas. Those proposed annual 

intake quantities were presented in units of becquerel (Bq) (see ER Addendum Table 7-1). For 

ease of comparison to the values presented in ORAUT-OTIB-0062, the units for the primary 

radionuclides, those for which bioassay data are abundant, have been converted to pCi/d in the 

table below. 

Conversion of LANL ER Addendum Annual Intake Values (Bq) to Daily Intake Values (pCi/d)

Radionuclide Lung Clearance 

Class

Annual Intake Quantity, 

2% SALI (Bq) 

(from ER Addendum)

Daily Intake Quantity, 

2% SALI (pCi/d)

U-234 D 1.36 x 103 100

U-234 W 4.69 x 102 35

U-234 Y 3.88 x 101 2.9

Pu-238 W 9.43 x 100 0.70

Pu-238 Y 1.28 x 101 0.95

Pu-239 W 8.62 x 100 0.64

Pu-239 Y 1.20 x 101 0.89

An intake value for tritium was not included in the above table because the values given, 

ORAUT-OTIB-0062, Table 5-1, are already in units of mrem per year, which may be compared 

directly to the 100 mrem CEDE proposed intake quantity. Table 5-1 from ORAUT-OTIB-0062 

shows annual tritium doses gradually trending lower from 1950 through 1988, at which time they 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 29 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

stabilized and remained relatively low. The 50th percentile annual doses for the applicable 

period, 1996-2005, based on actual bioassay data, range from 3 to 9 mrem per year. Assignment 

of 100 mrem per year for unmonitored workers potentially exposed to tritium appears to be 

bounding. 

For U-234, Pu-238, and Pu-239, the comparisons are not as straightforward. For these, intake 

quantities proposed in the ER Addendum for lung clearance classes D, W, and Y are compared 

to the 50th percentile intake rates presented in ORAUT-OTIB-0062 for lung clearance types F, 

M, and S, respectively. 

The following table shows a side-by-side comparison of ORAUT-OTIB-0062 uranium intakes to 

ER Addendum-proposed uranium intake rates, for the applicable time period. 

Comparison of ORAUT-OTIB-0062 vs. ER Addendum Uranium Intake Rates (pCi/d)

Time Period OTIB-0062

Type F

ER Add.

Class D

OTIB-0062

Type M

ER Add.

Class W

OTIB-0062 

Type S

ER Add.

Class Y

1996-2000 0.201 100 0.756 35 11.0 2.9

2001 1.019 100 4.70 35 92.0 2.9

2002-2005 0.201 100 0.756 35 11.0 2.9

A comparison of the OTIB-0062 Type F uranium intake rates to those proposed in the ER 

Addendum for Class D U-234 suggests that the ER Addendum intake rates are bounding. The 

same is true when comparing OTIB-0062 Type M intakes to Addendum Class W. This is not the 

case when comparing OTIB-0062 Type S to ER Addendum Class Y. It is important to keep in 

mind, however, the method by which the OTIB-0062 values were derived for Type S uranium. 

These values were produced from urine bioassay results. The underlying assumption is that the 

uranium found in the urine resulted from intakes of 100% pure Type S (highly-insoluble) 

material. In this case, a small amount of uranium in urine corresponds to a relatively large 

intake. It is also important to keep in mind here that no dose reconstruction infeasibilities have 

been identified for uranium intakes at LANL. For the case of uranium, bioassay data are 

available for monitored workers and ORAUT-OTIB-0062 (not necessarily 2% SALI) could be 

used to assign intakes for unmonitored workers with potential for exposure. This is also the case 

for tritium and plutonium intakes discussed in this section. The purpose for presenting these data 

and making these comparisons here is simply to show how intakes derived from actual bioassay 

results for the primary radionuclides would compare to 2% SALI intakes for these nuclides. Use 

of the 2% SALI (or 100 mrem CEDE) intake assumption would only be necessary for 

radionuclides for which dose reconstruction infeasibilities have been identified in Los Alamos 

National Laboratory (SEC-00109) Special Exposure Cohort Evaluation Report, Rev. 1, issued 

August 13, 2012 (NIOSH, 2012). 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 30 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

The OTIB-0062 50th percentile intake rates for Pu-238 for the 1996-2005 period are 0.048 and 

0.72 pCi/d for lung clearance Type M and S, respectively. The ER Addendum values for Class 

W and Y are 0.70 and 0.95. By this comparison, the proposed ER Addendum intake rates would 

appear to be bounding.

For Pu-239, the OTIB-0062 50th percentile intake rates for the 1996-2005 period are 0.013 pCi/d 

for Type M material and 0.14 pCi/d for Type S and Super S. The ER Addendum values for 

Class W and Y are 0.64 and 0.89. By this comparison, the proposed ER Addendum intake rates 

would appear to be bounding for Pu-239.

CONCLUSION

NIOSH agrees with many of the issues identified by SC&A in its review of the LANL ER 

Addendum. Specifically, NIOSH agrees that LANL may not have been in full compliance with 

all aspects of 10 CFR 835 during the entire period under evaluation (1996-2005). NIOSH further 

acknowledges the possibility that some workers who should have been monitored according to 

procedure, may not have been. 

NIOSH does not share many of SC&A’s technical concerns. Specifically, NIOSH did not 

identify any significant technical shortfalls with regard to LANL’s in-vivo program during the 

period of this evaluation. During the 10 CFR 835 era, the LANL in-vivo operation was equipped 

with state-of-the-art counting equipment and was staffed with competent professionals. As 

evidenced by available in-vivo measurement results, LANL used high-resolution germanium 

detectors throughout the entire evaluation period to monitor for fission and activation products 

for workers at the LANSCE facility and throughout the laboratory.

The field monitoring and contamination control programs at LANL were well-established and 

formalized by January 1, 1996. These programs, which were intended to ensure that 

unmonitored individuals were unlikely to receive intakes of 100 mrem CEDE, were in place and 

being implemented during the period of this evaluation.

Based upon its review of existing bioassay results, NIOSH finds that workers who were 

monitored for the primary radionuclides (uranium, plutonium, and tritium) were unlikely to have 

received intakes exceeding 2% of the SALI (or intakes that would have resulted in 100 mrem 

CEDE). NIOSH also believes that intakes to the unmonitored population would have been lower 

than that of the monitored population. NIOSH therefore concludes that unmonitored workers 

were unlikely to have received intakes of 2% of the SALI, and the assignment of 2% SALI 

intakes for unmonitored workers with access to controlled areas is bounding. NIOSH further 

finds no reason to believe that intakes of exotic radionuclides by unmonitored workers would be 

substantially different. In summary, NIOSH concludes that the weight of the evidence supports 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 31 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

assignment of 2% SALI intakes for unmonitored workers, as proposed in the ER Addendum, is 

sufficiently bounding and claimant favorable.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 32 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

REFERENCES

10 CFR 835, Occupational Radiation Protection, U.S. Department of Energy; SRDB Ref ID: 

173742

ABRWH, 2012a, Transcript: Advisory Board on Radiation and Worker Health, 86th Meeting, 

September 18, 2012; Denver, Colorado; SRDB Ref ID: 173738 

ABRWH, 2012b, Letter from James M. Melius, Chairman, ABRWH, to Kathleen 

Sebelius, Secretary of Health and Human Services. October 31, 2012; SRDB Ref ID:

169470 

Assessment, 1999, Assessment of the Los Alamos National Laboratory Internal Dose 

Evaluation Program, E. M. Brackett (MJW Corp.) and T. R. La Bone (Westinghouse 

Savannah River Co.); April 1, 1999; SRDB Ref ID: 168446, PDF pp. 132-138 

Cerro Grande, 2001, Updated Calculation of the Inhalation Dose from the Cerro Grande Fire 

Based on Final Air Data, LA-UR-01-1132, D.H. Kraig, et al, Los Alamos National 

Laboratory; February 2001; SRDB Ref ID: 46247 

DOE, 1988, Radiation Protection for Occupational Workers, DOE Order 5480.11, U.S. 

Department of Energy, Washington, DC. December 21, 1988; SRDB Ref. ID: 8073

DOE, 2001, Programmatic Assessment of the Internal Dosimetry Program at Los Alamos 

National Laboratory, 200-RP-1, U.S. Department of Energy, Los Alamos Area Office, Office 

of Facility Operations; July 5, 2001; SRDB Ref. ID: 83663 

DOE/NTS, 2017, Department of Energy Noncompliance Report, Main Information, NTSALO-LA-LANL-1999-0004, Internal Dose Evaluation Program, viewed on the 

Noncompliance Tracking System on July 5, 2017; SRDB Ref ID: 164555 

ES&H Manual, 1991, Environment, Safety, and Health Manual, Administrative Requirements: 

AR 3-6, Personnel Radiation Dosimetry; Los Alamos National; February 1991; SRDB Ref ID: 

51526 

LAMPF, 1975, An Assessment of Los Alamos Meson Physics Facility (LAMPF) Liquid 

Radioactive Waste Generation and Disposal Alternatives, Los Alamos Scientific Laboratory; 

July, 1975; SRDB Ref ID: 73423 

LAMPF, 1983, Major Dose Contributors at LAMPF, HD-83-42, memo to R. Miller (U.S. 

Department of Energy, Albuquerque Operations Office) from J. Aragon (Los Alamos National 

Laboratory); March 21, 1983; SRDB Ref ID: 73389 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 33 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

LANL, 1984, In Vivo Assessment of Lung Burdens at the Los Alamos National 

Laboratory, LA-9979-MS; Los Alamos National Laboratory; April 1984; SRDB Ref ID: 

12960 

LANL, 2013, Response to NIOSH Questions for LANL Staff Regarding 10 CFR 835 

Implementation and Unresolved Issues, RP2-HPM-13:002, Los Alamos National Laboratory, 

Radiation Protection Division, Los Alamos, NM; March 19, 2013; SRDB Ref. ID: 166130 

LANL Dosimetry, 1994, Laboratory Standard: Radiation Dosimetry Monitoring, LS107-11.0 

(Lab Doc Control No. 84); Los Alamos National Laboratory; December 23, 1994; SRDB Ref 

ID: 133601 

LANL Inspection, 2005, Inspection of Environment, Safety, and Health Programs at the 

Los Alamos National Laboratory, U.S. Department of Energy, Office of Security and Safety 

Performance Assurance, Office of Independent Oversight; November 2005; SRDB Ref ID: 

123968

NIOSH, 2012, SEC Petition Evaluation Report for Petition SEC-00109, Los Alamos National 

Laboratory, Rev. 1, National Institute for Occupational Safety and Health 

(NIOSH); August 13, 2012; SRDB Ref ID: 165232 

NIOSH, 2017, Addendum to Los Alamos National Laboratory (SEC-00109) Special Exposure 

Cohort Evaluation Report, National Institute for Occupational Safety and Health, (NIOSH). 

April 24, 2017; SRDB Ref ID: 173741 

Non-conformance, 1999, Noncompliance Report NC ID 484: Internal Dose Evaluation 

Program, NTS-ALO-LA-LANL-LANL-1999-0004; Los Alamos National Laboratory; 

March 1999; SRDB Ref ID: 164555 

NTS List, 2016, LANL-Associated Documents Potentially Related to 10 CFR 835 

Compliance Accessed for the DOE Nonconformance Tracking System (NTS), Oak Ridge 

Associated Universities; November 11, 2016; SRDB Ref ID: 165178 

ORAUT-OTIB-0062, Internal Dosimetry Coworker Data for Los Alamos National 

Laboratory, Rev. 00, Oak Ridge Associated Universities; October 15, 2009; SRDB Ref ID: 

75028 

ORAUT-OTIB-0063, Los Alamos National Laboratory Bioassay Repository Database, Rev. 

00, Oak Ridge Associated Universities; August 24, 2009; SRDB Ref ID: 73101 

ORAUT-OTIB-0066, Calculation of Dose from Intakes of Special Tritium Compounds, Rev. 

00, Oak Ridge Associated Universities; April 26, 2007; SRDB Ref ID: 31421 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 34 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

ORPS Reports, 1993-2015, LANL-Associated Documents Potentially Related to 10 CFR 

835 Compliance Accessed from the DOE Occurrence Reporting System (ORPS) for the 

Years 1993-2015, Oak Ridge Associated Universities; accessed from U.S. Department of 

Energy in 2017; SRDB Ref IDs: 165346 (1993); 165347 (1994-2006); 165348 (2007-2015) 

ORPS, 1998, LANL Occurrence Report:Americium-241 Contamination Detected on the 

Personal Clothing of an NMT-11 Employee Working in Wing 2, Room 2114 of the CMR 

Facility; ALO-LA-LANL-CMR-1998-0041; Los Alamos National Laboratory; November 

13, 1998; SRDB Ref ID: 168453, PDF pp. 220-225 (Contains UCNI and OUO)

ORPS, 2002, LANL Occurrence Report: Employees with Potential Uptake, One with Skin 

Contamination, After Airborne Release at Technical Area 55, Building 4, Room 319; DPALO-LA-LANL-TA55-2002-0003; Los Alamos National Laboratory; September 4, 2002; 

SRDB Ref ID: 164536, PDF pp. 18-26 

PNOV, 2007, Preliminary Notice of Violation and Proposed Civil Penalty of $1,100,000 

(Waived by Statute), EA-2006-05, U.S. Department of Energy, National Nuclear Security 

Administration; February 16, 2007; SRDB Ref ID: 46407 

Quarterly Report, 1988, Accelerator Health Protection Quarterly Progress Report, First 

Quarter -1988, Los Alamos National Laboratory; April 14, 1988; SRDB Ref ID: 45486 

SC&A, 2010, SC&A’s Review of NIOSH’s Evaluation Report for Los Alamos National 

Laboratory Special Exposure Cohort Petition SEC-00109: Preliminary Issues – Availability 

of Bioassay Records and Adequacy of In-vivo Dosimetry, SCA-TR-SEC2010-0004, Revision 

0, SC&A, Inc., Vienna, Virginia. April 8, 2010 ; SRDB Ref ID: 173739 

SC&A, 2017, Review of SEC Petition Evaluation Report Addendum (SEC-00109) for Los 

Alamos National Laboratory, SC&A, Inc.; July 27, 2017; SRDB Ref ID: 173740

Th-232 Bioassay, 1999, LANL Whole Body/Chest Count Dosimetry Report, Los Alamos National 

Laboratory; March 1999; SRDB Ref ID: 55138 

Tiger Team, 1991, Tiger Team Assessment of the Los Alamos National Laboratory, Washington, 

DC 20585, U.S. Department of Energy: Environment, Safety, and Health; November 1991; 

SRDB Ref ID: 23620 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 35 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has not been reviewed to identify and redact 

any information that is protected by the Privacy Act USC §552a and has not been cleared for distribution.

APPENDIX A: SEC-00109 LANL PETITIONER ISSUES AND RESOLUTIONS

This appendix provides a compilation of all the issues identified by the SEC-00109 

LANL petitioner along with their corresponding resolutions. The SEC-00109 

petitioner has, over the course of several years, identified an extensive array of 

concerns. These concerns involve monitoring, dosimetry, bioassay, data sufficiency, 

data integrity, site characteristics, exotic radionuclides, dose modeling, sites policies, 

and the role and attendant risks of Support Service Workers. 

When the petitioner filed his Form B petition in 2008, he provided a 102-page written 

narrative that discusses in detail a wide range of issues. He also provided a CD 

containing an enormous volume of site and third-party documentation that provides 

background information intended to support his concerns. Subsequent to the original 

submission, the petitioner physically attended, or called in, to meetings of the Advisory 

Board Work Group on LANL that were held on: 

• April 29, 2010;

• November 3, 2010;

• May 2, 2011;

• May 14, 2012;

• September 11, 2012; and

• August 15, 2017.

During these sessions, the petitioner identified additional concerns or elaborated on 

previous issues.

Following a page-by-page review of the original narrative and the transcripts of the 

Work Group meetings, NIOSH has compiled the petitioner’s issues in the following 

table. NIOSH then assessed whether each issue has been addressed in the appropriate 

manner in some document or venue. The issues are presented in the chronological 

order in which they were raised, beginning with the original narrative and going 

through the six meeting transcripts.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 36 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

SEC-00109 LANL Petitioner Issues

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

1 Multiple documented admissions by 

NIOSH that there are still unresolved 

issues at the site after 1975

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 11-12, 51

Received

04-03-08

SEC-00051, PDF pp. 74, 

110

May 3, 2007 Board meeting, 

PDF pp. 274, 302-304

NIOSH concurred with the petitioner. SEC-00109 

ER, Rev. 1 (08-13-12), recommended expanding 

the SEC class through 1995. 

2 Poor monitoring or lack of monitoring 

of the support service workers

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 12, 44-46

Received

04-03-08

SEC-00051, PDF pp. 74, 

110

LANL’s Air Emissions 

Monitoring Program, pp. 8-

14

NIOSH concurred with the petitioner. SEC-00109 

ER, Rev. 1 (08-13-12), recommended expanding 

the SEC class through 1995.

3 Dosimetry deficiencies SEC-00109 Petition 

Attached Narrative, 

PDF p. 13

Received

04-03-08

None provided or referenced NIOSH concurred with the petitioner. SEC-00109 

ER, Rev. 1 (08-13-12), recommended expanding 

the SEC class through 1995.

4 Bioassay deficiencies SEC-00109 Petition 

Attached Narrative, 

PDF p. 13

Received

04-03-08

None provided or referenced NIOSH concurred with the petitioner. SEC-00109 

ER, Rev. 1 (08-13-12), recommended expanding 

the SEC class through 1995.

5 Insufficient data and poor methodology 

for reconstructing environmental dose

SEC-00109 Petition 

Attached Narrative, 

PDF p. 13

Received

04-03-08

None provided or referenced NIOSH concurred with the petitioner. SEC-00109 

ER, Rev. 1 (08-13-12), recommended expanding 

the SEC class through 1995.

6 The site is very large (8.6 M sq. ft. in 

about 2000 structures), which makes 

analysis a challenge

SEC-00109 Petition 

Attached Narrative, 

PDF p. 13

Received

04-03-08

None provided or referenced NIOSH acknowledges that LANL is a large site. 

This fact, however, would not likely affect the 

ability to reconstruct dose for monitored workers.

7 LANL is topographically complex, 

which makes site meteorology highly 

variable

SEC-00109 Petition 

Attached Narrative, 

PDF p. 16

Received

04-03-08

None provided or referenced NIOSH acknowledges that LANL is 

topographically complex. This fact, however, 

would not likely affect the ability to reconstruct 

dose for monitored workers.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 37 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

8 LANL climate and terrain make 

radionuclide dispersion highly variable

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 16, 26

Received

04-03-08

None provided or referenced NIOSH agrees. This issue affects the accuracy of 

dispersion modeling; however does not affect the 

ability to reconstruct worker intakes based upon 

workplace sampling. 

9 The LANL Site Profile assumes that 

outdoor explosives testing is an area 

source. The column of entrainment 

should be considered a point source, 

which should be modeled differently.

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 24, 28-29

Received

04-03-08

Final Environmental Impact 

Statement for the Dual Axis 

Radiographic 

Hydrodynamic Test 

(DARHT) Facility

The Occupational Environmental Dose volume of 

the Site Profile, ORAUT-TKBS-0010-4, mentions 

“...area sources (such as contaminated soil)...” 

(PDF p. 50). This is the only mention of area 

sources in the profile. Worker intake estimates do 

not rely upon plume dispersion models. 

Environmental intake estimates in outdoor 

explosives testing areas are based on air monitoring 

data. Post-1995, workers likely to receive intakes 

resulting in 100 mrem CEDE should have been 

monitored. (Note: The LANL Site Profile was 

revised in 2010.)

10 Buildings influence dispersion SEC-00109 Petition 

Attached Narrative, 

PDF p. 24

Received

04-03-08

None provided or referenced Worker intake estimates do not rely on plumedispersion models. Environmental intake estimates 

in outdoor areas are based on air monitoring data. 

Post-1995, workers likely to receive intakes 

resulting in 100 mrem CEDE should have been 

monitored.

11 The CAP-88 Model has limitations that 

affect accuracy when applied to LANL.

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 34-36

Received

04-03-08

None provided or referenced Worker intake estimates do not rely on plumedispersion models. Environmental intake estimates 

in outdoor areas are based on air monitoring data. 

Post-1995, workers likely to receive intakes 

resulting in 100 mrem CEDE should have been 

monitored. (Note: The LANL Site Profile was 

revised in 2010. There is no mention of the CAP88 Model in the current version.) 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 38 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

12 Few AIRNET samplers are placed in 

locations that would determine 

employee exposures. They are located 

to estimate off-site exposure.

SEC-00109 Petition 

Attached Narrative, 

PDF p. 38

Received

04-03-08

SC&A’s LANL Site Profile 

Review, SCA-TR-Task1-

0011

The cited SC&A review of the 2004 Site Profile 

was completed in 2006. The 2010 revised LANL 

Site Profile addressed this issue.

13 In the DOE environmental surveys of 

all its sites, LANL was the 4th highest 

in problems with 59.

SEC-00109 Petition 

Attached Narrative, 

PDF p. 39

Received

04-03-08

GAO 90-101, ES&H 

Problems at DOE Sites, p. 

20

NIOSH does not disagree that there were 

environmental problems at LANL, as identified in 

the cited 1987 report. However, these problems 

would not affect NIOSH’s ability to reconstruct 

worker doses that are based on monitoring data.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 39 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

14 There were a number of findings by the 

Tiger Team that relate to monitoring, 

dose, and missed dose.

SEC-00109 Petition 

Attached Narrative, 

PDF p. 40

Received

04-03-08

GAO 93-66, Corrective 

Actions on Tiger Team 

Findings Progressing 

Slower than Planned, p. 5

This issue was addressed in SEC-00109 ER, Rev. 0 

(01-22-09), and in SEC-00109 ER, Rev. 1 (08-13-

12). The Tiger Team Assessment Report

(submitted by the petitioner) made a number of

observations about the LANL site that are pertinent 

to the potential for unmonitored intakes (Tiger 

Team, 1991). In summary, the report observed that: 

1. radiation surveys sometimes did not conform to

LANL policies and documented schedules;

2. contamination control programs did not ensure

complete control of the spread of contamination;

3. there were instances in which barriers had been

removed or signage was inappropriate or missing;

4. posting was inconsistent throughout the site;

5. the frequency of surveys mandated by procedures

was not consistently followed;

6. signs and labels throughout the plutonium and

uranium facilities did not indicate radiological

conditions, were not accurate, or had other

problems that could lead to unsafe practices;

7. documentation of smear surveys was not

consistently performed;

8. the use of open-front hoods led to an increased

frequency of radioactive material contamination

incidents;

9. cracked glovebox gloves were observed;

10. removable and fixed surface contamination limits

for tritium and pure gamma-emitting nuclides were

not in compliance with DOE Order 5480.11;

(continued on next page)
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 40 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

14 (continued) (continued) (continued) (continued) (continued) 

11. calibration and response-checking of fixed

instruments and tritium monitors did not reflect

the same level of attention and commitment

given to portable instrumentation;

12. out-of-calibration instruments, such as glovebox

hand and foot monitors and tritium monitors,

were not placed out of service;

13. placement of air monitoring instruments at the

DU sites was not based on studies of flow

patterns;

14. facility air monitor alarm points, used per DOE

Order 5480.11 to warn workers that airborne

radioactive material contamination levels had

exceeded an action level, were not always set at

a uniform level, with the set points varying from

monitor to monitor even in the same building;

and

15. training programs had not been established to

ensure that routine dose rate and contamination

surveys were conducted in a consistent manner.

None of the numerous Tiger Team findings and 

observations pertains to the adequacy of the internal 

or external dose personnel monitoring programs; 

therefore, they do not compromise NIOSH’s ability 

to conduct dose reconstruction with sufficient 

accuracy. Dose reconstructions for LANL 

employees are based on internal and external dose 

monitoring data. These data are also employed in 

co-worker studies to estimate unmonitored worker 

intakes.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 41 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

15 The LANL ES&H Self-Assessment 

identified problems with stack 

monitoring and LANL lost a Clean Air 

Act lawsuit as a result.

SEC-00109 Petition 

Attached Narrative, 

PDF p. 41

Received

04-03-08

LA-12200-MS, 

Finding/AX.2-1 

NIOSH does not disagree that there were stackmonitoring problems at LANL, as identified in the 

cited 1991 ES&H Self-Assessment report. 

However, these problems would not affect 

NIOSH’s ability to reconstruct worker doses using 

methodologies that do not rely on stack monitoring.

16 The EPA found that LANL was not in 

compliance in regard to identifying 

emission sources, installation of stacks, 

and stack monitoring.

SEC-00109 Petition 

Attached Narrative, 

PDF p. 42 

Received

04-03-08

None provided or referenced NIOSH does not disagree that there were stackmonitoring problems at LANL. However, these 

problems would not affect NIOSH’s ability to 

reconstruct worker doses using methodologies that 

do not rely on stack monitoring.

17 An EPA audit the following year found 

continuing violations. 31 of 33 

radionuclide-emitting stacks were out 

of compliance. LANL was fined and 

had to submit 3 independent audits of 

its air quality.

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 42-43

Received

04-03-08

Memorandum Opinion and 

Order, p. 8

See response to Issue 16.

18 The main resources for the dosing 

tables in ORAUT-TKBS-0010-4 were 

the CDC’s LAHDRA report and the 

LANL Environmental Surveillance 

Report, both of which only address 

airborne concentrations that would 

affect people off-site.

SEC-00109 Petition 

Attached Narrative, 

PDF p. 47

Received

04-03-08

ORAUT-TKBS-0010-4 

SEC-00051 ER, PDF p. 81

This issue is from the 2004 Site Profile. The profile 

was revised in 2010. Section 4.2.1.1 of ORAUTTKBS-0010-4 (03-26-10) states: For earlier years 

(1943 to 1970), the effluent releases in this 

document rely on data from the Centers for Disease 

Control and Prevention Los Alamos Historical 

Document Retrieval and Assessment (LAHDRA) 

project (ENSR 2002), including unpublished data; 

however, these data were determined to be 

insufficient for reconstruction of environmental 

internal doses.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 42 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

19 Prior to the Clean Air Act in 1969, 

LANL did not maintain effluent data.

SEC-00109 Petition 

Attached Narrative, 

PDF p. 50

Received

04-03-08

CDC’s LAHDRA report The SEC-00109 evaluation addressed the years 

1976-2005. This pre-1969 issue is not relevant. 

20 Current policies and procedures do not 

ensure compliance with DOE Order 

5480.19.

SEC-00109 Petition 

Attached Narrative, 

PDF p. 53

Received

04-03-08

LANL ES&H SelfAssessment, OA.7-1, 

Document Control

This 1991 Self-Assessment identified compliance 

issues with DOE Order 5480.19, “Conduct of 

Operations Requirements for DOE Facilities.” 

NIOSH also found issues associated with written 

operating procedures. Expansion of the SEC class 

through 1995 was recommended in the SEC-00109 

ER, Rev. 1 (08-13-12). Radiation protection and 

monitoring procedures improved by 1996, with the 

implementation of 10 C.F.R. 835.

21 LANL does not have a clearly 

articulated policy with standards for 

procedure development, document 

control, and records management.

SEC-00109 Petition 

Attached Narrative, 

PDF p. 54

Received

04-03-08

LANL ES&H SelfAssessment, OA.7-2, 

Document Control

This 1991 Self-Assessment identified compliance 

issues with DOE Order 5480.19, “Conduct of 

Operations Requirements for DOE Facilities.” 

NIOSH also found issues associated with 

procedures and records management. Expansion of 

the SEC class through 1995 was recommended in 

the SEC-00109 ER, Rev. 1 (08-13-12). Radiation 

protection and records management procedures 

improved by 1996, with the implementation of 10 

C.F.R. 835.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 43 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

22 There is a lack of data for the Cerro 

Grande Fire for a variety of reasons. 

Security guards were not provided with 

any breathing apparatus throughout the 

three weeks of the fire and evacuation 

and return and they worked 16 hrs/day 

7 days/wk.

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 55-63

Received

04-03-08

GAO/T-RCED-00-273

National Research Council 

Radiation report

LA-UR-01-1132

SEC-00109 ER, Rev. 0 (01-22-09), and SEC-00109 

ER, Rev. 1 (08-13-12), address the Cerro Grande 

Fire in Section 7.4.1. A study performed soon after 

the Cerro Grande fire included two dose 

calculations: 

1. the hypothetical maximally-exposed firemen

or volunteer who was working actively in the

Los Alamos area throughout the worst of the

burn duration; and

2. the maximally-exposed member of the public

outside Los Alamos. Those calculations are

updated in Updated Calculations of the

Inhalation Dose from the Cerro Grande Fire

Based on Final Air Data (Cerro Grande, 

2001). 

In addition, a third calculation is added: a fireman 

or other worker in the vicinity of AIRNET 

(LANL’s ambient air monitoring network) Station 

#23 in Mortandad Canyon where elevated levels of 

LANL-derived airborne uranium occurred during 

the peak of the fire. The incident information was 

reviewed by NIOSH and these data can be used to 

bound the dose for any Service Support Worker 

who might have been exposed during the fire.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 44 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

23 Support service workers were not 

monitored or adequately monitored 

during and after the Sigma Americium 

Contamination Incident.

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 63-65

Received

04-03-08

Type B Investigation

NCRP Report No. 87

SEC-00051 LANL ER, PDF 

pp. 67, 78

SEC-00109 ER, Rev. 0 (01-22-09), and SEC-00109 

ER, Rev. 1 (08-13-12), address the Sigma American 

Contamination Incident in Section 7.4.2. The Type 

B Accident Investigation report on the July 14, 

2005 americium contamination accident at the 

LANL Sigma Facility states that the maximum dose 

to Worker 1 (the maximally-exposed individual) 

was 500 mrem CEDE. Based on this assessment 

and its review by NIOSH, a maximum intake may 

be estimated, which could then be used to bound the 

dose for service workers.

24 In-vitro bioassay samples were not 

handled properly. They were stored in 

an unrefrigerated cabinet and analyzed 

once a week.

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 65-66

Received

04-03-08

NCRP Report No. 87 NIOSH has not identified sample-handling issues 

that would invalidate bioassay results. 

25 The LANL bioassay program was 

insufficient because support service 

workers were not routinely monitored 

and the records are inadequate or 

incomplete.

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 66-68

Received

04-03-08

SEC-00051 LANL ER, PDF 

pp. 67, 78

NIOSH concurred with the petitioner. SEC-00109 

ER, Rev. 1 (08-13-12), recommended expanding 

the SEC class through 1995. Post-1995, workers 

likely to receive intakes resulting in 100 mrem 

CEDE should have been monitored. 

26 Because support service workers could 

work at several facilities in a day, and 

because NCFs varied by more than an 

order of magnitude across LANL 

facilities, data from the LANL 7776 

type TLD cannot be used for DRs for 

these workers.

SEC-00109 Petition 

Attached Narrative, 

PDF pp. 68-69

Received

04-03-08

Hoffman and Mallett, p. 

S98

This issue was addressed in SEC-00109 ER, Rev. 0 

(01-22-09) and SEC-00109 ER, Rev. 1 (08-13-12), 

in Section 7.4.4. Area-specific neutron correction 

factors (NCFs) are used at LANL to improve the 

accuracy of the neutron dose based on workplace 

instrument measurements (ORAUT-TKBS-0010-6). 

If workers frequented multiple facilities, or if the 

facilities frequented are unknown, NIOSH can 

bound neutron doses by applying the highest NCF 

for any of the buildings the worker may have 

entered. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 45 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

27 Regarding the validity of coworker 

data, I have concerns about the firing 

sites. There were explosions involving 

exotics. What workers are you using to 

represent the people who were there 

and who cleaned up? All site workers?

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 240-242

April 29, 

2010

None provided or referenced The coworker models were derived from bioassay 

results from all monitored workers at LANL, not 

just glovebox workers.

28 Are the electronic data present to 

validate who was in an area and when?

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 242-244

April 29, 

2010

None provided or referenced NIOSH does not rely on electronic data to 

determine who is in various LANL areas. NIOSH 

acknowledges that many workers frequented 

multiple unknown areas. For this reason, the SEC 

class definition in SEC-00109 ER, Rev. 1 (08-13-

12), includes all workers. In the SEC-00109 ER 

Addendum (04-24-17), NIOSH concluded that 

unmonitored workers were unlikely to have 

received intakes that would have resulted in 100 

mrem CEDE.

29 What about the checklist that workers 

fill out annually that is part of the 

occupational health program? It asks 

what radionuclides a worker is exposed 

to. If workers don’t know, they will 

generally say No. Does this checklist 

determine who is identified for 

monitoring and the bioassay program?

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 244-249

April 29, 

2010

None provided or referenced In the SEC-00109 ER Addendum (04-24-17), 

NIOSH concluded that the LANL programs for 

identifying individuals for bioassay during the post1995 era were effective. NIOSH further concluded 

that unmonitored workers were unlikely to have 

received intakes that would have resulted in 100 

mrem CEDE.

This issue was identified by SC&A in their review 

of the LANL ER Addendum. It is being further 

evaluated and will be addressed in the White Paper 

being prepared in response to the SC&A review. 

This was one of the issues identified in the 

noncompliance report NC ID 484.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 46 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

30 I still don’t feel all the source terms 

environmentally have been identified 

and examined. I related them in my 

report. I don’t feel they were addressed 

in the ER.

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 249-250

April 29, 

2010

None provided or referenced In the SEC-00109 ER Addendum (04-24-17), 

NIOSH concluded that unmonitored workers were 

unlikely to have received intakes that would have 

resulted in 100 mrem CEDE. This determination 

includes contributions from environmental 

contamination source terms.

31 The New Mexico Environment Dept. 

and LANL are supposed to issue a joint 

report concerning contamination at the 

lab. They have determined that the DO 

need a federal investigation where it is 

compensable to surrounding lands.

Transcript from the 

Board meeting of 

April 29, 2010, PDF p. 

249

April 29, 

2010

None provided or referenced In the SEC-00109 ER Addendum (04-24-17), 

NIOSH concluded that unmonitored workers were 

unlikely to have received intakes that would have 

resulted in 100 mrem CEDE. This determination 

includes contributions from environmental 

contamination source terms.

32 Talking about LANSCE and the 

activation product issues, in my 

petition, there is a discrepancy between 

that and I believe the latest update to 

the environmental exposures in the 

TBD because basically they say the 

winds going to TA-72 are three 

percent. And in the petition, I provide 

documentation that says the winds 

going towards TA-72 are 26 percent.

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 250-251

April 29, 

2010

None provided or referenced In the SEC-00109 ER Addendum (04-24-17), 

NIOSH concluded that unmonitored workers were 

unlikely to have received intakes that would have 

resulted in 100 mrem CEDE. This determination 

includes contributions from environmental 

contamination source terms.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 47 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

33 LANL cited one air monitor in 

Mortandad Canyon they would use to 

determine dose for firefighter, guards, 

and other people on site. The RAC 

report stated that air monitors were shut 

off for 3 days during the fire. 

Particulate matter overwhelmed the 

filters so that accuracy was changed by 

an order of magnitude.

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 252-255

April 29, 

2010

None provided or referenced See response to Issue 22.

The report referenced in response to Issue 22,

Updated Calculations of the Inhalation Dose from

the Cerro Grande Fire Based on Final Air Data 

(Cerro Grande, 2001), concluded that the 

maximally-exposed individual from this fire 

received an intake resulting in a CEDE of only a 

fraction of a mrem. It is unlikely that 

unmonitored workers received intakes in excess of 

100 mrem CEDE. 

34 Worker records that did not record 

locations where people worked. They 

just recorded pay code and hours 

worked. Only in the last few years, 

were work locations recorded.

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 257-258

April 29, 

2010

None provided or referenced NIOSH recognizes that claimants’ specific work 

locations are often unknown. For this reason, the 

SEC class definition in SEC-00109 ER, Rev. 1 (08-

13-12), includes all workers and all areas. In the

SEC-00109 ER Addendum (04-24-17), NIOSH

concluded that unmonitored workers were unlikely

to have received intakes that would have resulted in

100 mrem CEDE.

35 It was revealed in the Clean Air Act 

lawsuit that there were several 

buildings with unmonitored stacks. 

Were there exotics in these buildings?

Transcript from the 

Board meeting of Nov. 

3, 2010, PDF pp. 133-

134

Nov. 3, 

2010

None provided or referenced NIOSH does not disagree that there were stack 

monitoring problems at LANL. However, these 

problems would not affect NIOSH’s ability to 

reconstruct worker doses using methodologies that 

do not rely on stack monitoring.

36 The episodic nature of the release of 

exotics through unmonitored stacks.

Transcript from the 

Board meeting of Nov. 

3, 2010, PDF pp. 165-

166

Nov. 3, 

2010

None provided or referenced See response to Issue 35.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 48 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

37 A guy inside a building has a glovebox 

and negative pressure. Where is 

contamination going? Out an 

unmonitored stack to a guy who is 

mowing the lawn.

Transcript from the 

Board meeting of Nov. 

3, 2010, PDF pp. 168-

169

Nov. 3, 

2010

None provided or referenced Intakes by a person mowing the lawn would be 

accounted for by using methodologies given in the 

Site Profile for assigning environmental dose. 

38 How do you place service workers at 

the firing sites before and after 

explosions (e.g., during clean-up)? 

There are problems with the badging 

process in making that determination.

Transcript from the 

Board meeting of Nov. 

3, 2010, PDF pp. 292-

297

Nov. 3, 

2010

None provided or referenced NIOSH will use personal monitoring data when 

available to assign worker doses and intakes. 

NIOSH does not rely on knowledge of worker 

location during and after explosives tests. In the 

SEC-00109 ER Addendum (04-24-17), NIOSH 

concluded that unmonitored workers were unlikely 

to have received intakes that would have resulted in 

100 mrem CEDE.

39 There is a question about the reliability 

of Occupational Health and Health 

Physics checklists. The OH checklist 

is self-reporting. The HP checklist is 

informing in regard to whether 

bioassay will be required. Are these 

considered administrative controls? 

Are we relying on these to determine 

where people worked and when?

Transcript from the 

Board meeting of Nov. 

3, 2010, PDF pp. 299-

310, 338-341

Nov. 3, 

2010

None provided or referenced The Board conversation seems to say that NIOSH is 

NOT using these documents to make these 

determinations.

NIOSH does not rely on the HP checklists to 

determine when and where individuals worked. 

The checklists are used, in part, by LANL HP 

professionals to ensure that workers are placed on 

the appropriate personnel monitoring programs.

Concerns regarding the effectiveness of the HP 

checklists for identifying appropriate bioassay 

programs for workers were raised by SC&A in their 

review of the LANL ER Addendum. The issue is 

being further evaluated and will be addressed in the 

White Paper being prepared in response to that 

SC&A review. This was one of the issues 

identified in the non-compliance report NC ID 484.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 49 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

40 There are a number of sites that are 

uncharacterized. They don’t know 

what’s in them. There is exposure 

potential there, at least for service 

workers.

Transcript from the 

Board meeting of Nov. 

3, 2010, PDF pp. 315-

319

Nov. 3, 

2010

None provided or referenced For monitored workers at uncharacterized sites, 

NIOSH would use those monitoring results to 

assign doses and intakes. In the SEC-00109 ER 

Addendum (04-24-17), NIOSH concluded that 

unmonitored workers were unlikely to have 

received intakes that would have resulted in 100 

mrem CEDE.

41 The National Academy of Sciences 

report says there is no mass balance for 

LANL. That raise the question: Have 

you captured the entire source term and 

potential exposure to workers?

Transcript from the 

Board meeting of Nov. 

3, 2010, PDF p. 315

Nov. 3, 

2010

None provided or referenced Accurate knowledge of source terms can sometimes 

be helpful to bound potential intakes in the absence 

of monitoring data. For LANL, NIOSH relies on 

monitoring data to assign intakes, but also 

recognizes that some workers were not monitored. 

In the SEC-00109 ER Addendum (04-24-17), 

NIOSH concluded that unmonitored workers were 

unlikely to have received intakes that would have 

resulted in 100 mrem CEDE.

42 Cerro Grande fire discussion and Don 

Stewart’s white paper.

Transcript from the 

Board meeting of Nov.

3, 2010, PDF pp. 321-

333

Nov. 3, 

2010

None provided or referenced See response to Issue 22.

43 The Tiger Team findings are 

programmatic. They call into question 

the reliability of the data for what you 

intend to use the data for. 

Transcript from the 

Board meeting of Nov. 

3, 2010, PDF pp. 336-

344

Nov. 3, 

2010

None provided or referenced This issue was addressed in SEC-00109 ER, Rev. 0 

(01-22-09). See response to Issue 14.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 50 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

44 Are uncharacterized areas (e.g., waste 

disposal sites) covered under 

environmental? There is a listing of 

sites that require further investigation 

to determine if the pose a threat. The 

petitioner lists many examples.

Transcript from the 

Board meeting of May 

2, 2011, PDF pp. 286-

293

May 2, 

2011

None provided or referenced For monitored workers in uncharacterized areas, 

NIOSH would use those monitoring results to 

assign doses and intakes. In the SEC-00109 ER 

Addendum (04-24-17), NIOSH concluded that 

unmonitored workers were unlikely to have 

received intakes that would have resulted in 100 

mrem CEDE.

45 As a result of the Clean Air Act 

lawsuit, they had an audit team that 

determined that a lack of 

documentation regarding inventories 

precluded a thorough evaluation 

regarding the quality and completeness 

of the 1996 inventory. Also, they 

questioned the historical data on 

release and stack monitoring. 

Additional issue recited.

Transcript from the 

Board meeting of May 

2, 2011, PDF pp. 293-

298

May 2, 

2011

None provided or referenced This issue is unlikely to impact NIOSH’s ability to 

reconstruct dose to workers. NIOSH utilizes 

personnel monitoring data for dose reconstruction at 

LANL, not inventories or stack monitoring data. In 

the SEC-00109 ER Addendum, 4/24/17, NIOSH 

concluded that unmonitored workers were unlikely 

to have received intakes that would have resulted in 

100 mrem CEDE.

46 In discussions with the petitioner, the 

firefighters maintain they had no 

bioassay samples taken during or after 

the Cerro Grande fire.

Transcript from the 

Board meeting of May 

2, 2011, PDF pp. 310-

315

May 2, 

2011

None provided or referenced See response to Issue 22.

47 The issue of the size of the in vivo 

datasets in regard to exotics. There is a 

lot for U, Pu, and Am, but not for 

exotics. Are the datasets representative 

for exotics in terms of DR?

Transcript from the 

Board meeting of May 

2, 2011, PDF pp. 318-

322

May 2, 

2011

None provided or referenced NIOSH concurred with this issue in SEC-00109 

ER, Rev. 1 (08-13-12), when it recommended an 

SEC class through 1995. In the SEC-00109 ER 

Addendum (04-24-17), NIOSH concluded that 

unmonitored workers were unlikely to have 

received intakes from exotic radionuclides that 

would have resulted in 100 mrem CEDE.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 51 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

48 The issue of RWPs and SWPs and 

whether they are always used and 

properly used when they are used. 

What about service workers who are 

not on an RWP?

Transcript from the 

Board meeting of May 

14, 2012, PDF pp. 

137-150

May 14, 

2012

None provided or referenced NIOSH concurred with this issue in SEC-00109 

ER, Rev. 1 (08-13-12), when it recommended an 

SEC class through 1995. In the SEC-00109 ER 

Addendum (04-24-17), NIOSH concluded that 

unmonitored workers were unlikely to have 

received intakes from exotic radionuclides that 

would have resulted in 100 mrem CEDE.

Concern regarding the effectiveness of RWPs for 

identifying appropriate bioassay programs for 

workers was raised by SC&A in their review of the 

LANL ER Addendum. This issue is being further 

evaluated and will be addressed in the White Paper

being prepared in response to the SC&A review. 

This was one of the issues identified in the 

noncompliance report NC ID 484.

49 The measurement techniques for Pu 

don’t translate for Np. A wide-ranging 

discussion revolving around 

unmonitored workers.

Transcript from the 

Board meeting of May 

14, 2012, PDF pp. 

207-221

May 14, 

2012

None provided or referenced This issue was addressed in a six-page response in 

the SEC-00109 ER Addendum (04-24-17).

50 In the 2008 report by DOE HSS (page 

5), they said that at the institutional 

level, methods used to enroll workers 

in the bioassay program have not been 

adequate to ensure that workers are 

monitored for correct isotopes and at 

the required frequencies. Question 

about NIOSH’s programmatic 

argument.

Transcript from the 

Board meeting of May 

14, 2012, PDF pp. 

244-246

May 14, 

2012

None provided or referenced Concern regarding the effectiveness of the methods 

used to enroll workers in the appropriate bioassay 

programs was raised by SC&A in their review of 

the LANL ER Addendum. This issue is being 

further evaluated and will be addressed in the White 

Paper being prepared in response to the SC&A 

review. This was one of the issues identified in the 

noncompliance report NC ID 484.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 52 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

51 At what point do you establish that the 

hole is too big and it seems you are not 

looking for these (exotic) radionuclides 

to begin with. If you are not looking 

for them, how do you establish a dose?

Transcript from the 

Board meeting of May 

14, 2012, PDF pp. 

249-252

May 14, 

2012

None provided or referenced NIOSH concurred with this issue in SEC-00109 

ER, Rev. 1 (08-13-12), when it recommended an 

SEC class through 1995. In the SEC-00109 ER 

Addendum (04-24-17), NIOSH concluded that 

unmonitored workers were unlikely to have 

received intakes from exotic radionuclides that 

would have resulted in 100 mrem CEDE.

52 Re the response doc: How is the 

co-worker model going to fly for the 

firing sites when the model deals with 

glovebox workers and the firing sites 

are open areas with resuspension 

issues? 

Transcript from the 

Board meeting of May 

14, 2012, PDF pp. 

286-292

May 14, 

2012

None provided or referenced The co-worker models were derived from bioassay 

results from all monitored workers at LANL, not 

just glovebox workers.

53 More discussion of Cerro Grande. Transcript from the 

Board meeting of May 

14, 2012, PDF pp. 

293-297

May 14, 

2012

None provided or referenced See response to Issue 22.

54 No issues discussed by petitioner 

during this meeting.

Transcript from the 

Board meeting of 

Sept. 11, 2012

Sept. 11, 

2012

None provided or referenced No issue, no resolution.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 53 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

55 Concern about spallation products from 

the accelerator.

Transcript from the 

Board meeting of Aug. 

15, 2017, PDF p. 87

Aug. 15, 

2017

None provided or referenced A 1975 assessment identifies spallation products in 

LAMPF waste water (LAMPF, 1975). It lists C-10, 

O-14, O-15, N-13, C-11, Be-7, and H-3 as spallation 

products.

A 1982 memo discusses public doses from LAMPF 

(1983). C-11, N-13, and O-15 are identified as the 

major dose contributors. 

A health protection quarterly progress report for Q1 

1988 summarizes the 1987 Area A stack releases 

(Quarterly Report, 1988), as follows: 

The total quantity of gaseous radioactivity released 

to the atmosphere from the Area A stack during the

1987 operating period was 150,000 Curies. The

composition of this gaseous effluent was as follows:

Isotope Half-Life Percentage

Nitrogen-16 7.1 s 3.7

Carbon-10 19.3 s 1.4

Oxygen-14 1.2 m 0.6

Oxygen-15 2.0 m 43.7

Nitrogen-13 10.0 m 15.1

Carbon-11 20.4 m 35.1

Argon-41 109.7 m 0.4

In addition, approximately 13 Curies of tritium 

[H-3] as water vapor was released in 1987.

(continued on next page)
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum

September 12, 2018

Page 54 of 54

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution.

Issue Petitioner Issue Forum Date

Supporting Document(s) 

Provided or Referenced 

by Petitioner

Resolution

55 (continued) (continued) (continued) (continued) (continued)

For dose reconstruction purposes, NIOSH has 

numerous bioassay results for LANSCE that

include assay for Be-7, C-11/N-13, and several 

other activation products (as shown in Table 4-1 in 

this white paper).

Given the short half-lives of the spallation products 

(listed above), NIOSH considers that these products 

were unlikely to have been significant contributors 

to worker doses.

56 Question about Np. Was it only in TA55 or were there other areas? If so, was 

100 grams the maximum?

Transcript from the 

Board meeting of Aug. 

15, 2017, PDF p. 87

Aug. 15, 

2017

None provided or referenced The neptunium issue was addressed in the SEC0009 Addendum (04-24-17). 

This specific issue was also raised by SC&A in 

their Review of SEC Petition Evaluation Report 

Addendum (SEC-00109) for Los Alamos National 

Laboratory (07/27/17). NIOSH is currently 

preparing a White Paper response to that SC&A 

review. A response to this specific question will be 

included in that White Paper.

57 The catalog for the in vivo 

measurements is very limited or nonexistent so you don’t have the ability to 

determine if someone was exposed to 

an exotic as opposed to a common 

ROC.

Transcript from the 

Board meeting of Aug. 

15, 2017, PDF p. 88

Aug. 15, 

2017

None provided or referenced Post-1995, LANL has maintained the technical 

capability to identify specific radionuclides in 

bioassay analyses for monitored workers. In the 

SEC-00109 ER Addendum (04-24-17), NIOSH 

concluded that unmonitored workers were unlikely 

to have received intakes from exotic radionuclides 

that would have resulted in 100 mrem CEDE.